IMSML Website Article 14/2025: Resolution MEPC.378(80) - 2023 Guidelines for the Control and Management of Ships’ Biofouling to Minimise the Transfer of Invasive Aquatic Species
Resolution MEPC.378(80) was adopted by the International Maritime Organisation’s (IMO) Marine Environment Protection Committee (MEPC) at its 80th Session. The MEPC’s resolution was a clear commitment to minimizing the transfer of invasive aquatic species by shipping as documented in the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004. The resolution recognises that ‘the transfer of invasive aquatic species, if established in new ecosystems, may pose threats to the environment, human health, property and resources’. The initiative is an attempt at ‘reducing the risk of transfer of invasive aquatic species’ and promotes ‘a globally consistent approach to the management of biofouling’, see Paragraph 1.1.
The 2023 Guidelines for the Control and Management of Ships’ Biofouling to Minimise the Transfer of Invasive Aquatic Species consists of 14 distinct sections, abbreviations, and 4 appendices.
SECTION 1 - INTRODUCTION
Is biofouling a significant vector for the transfer of invasive aquatic species? Yes. Biofouling results in the establishment of invasive aquatic species, which may pose threats to human, animal and plant life, as well as economic and cultural activities, and the aquatic environment, see Paragraph 1.3.
What bodies recognise that invasive aquatic species pose a major threat for the well-being of oceans? Paragraph 1.4 identifies the following bodies:
[1] Convention on Biological Diversity;
[2] Several UNEP Regional Seas Conventions;
[3] The Asia Pacific Economic Cooperation Forum; AND …
[4] The Secretariat of the Pacific Region Environmental Programme.
How do the Guidelines deal with the complexity of risk involving invasive species? Biofouling starts within the first few hours of a ship’s immersion in water and is influence by the following (see Paragraph 1.5):
[1] Design and construction of the ship’s hull and niche areas;
[2] Operating profile of the ship and its maintenance history.
What are the management steps / practices for reduction of biofouling? Paragraph 1.6 identifies the following:
[1] Attention during the initial ship design and construction;
[2] Implementation of Anti-Fouling Systems (AFS) for all parts of a ship that are submerged, or has wetted surface areas (including hull or niche areas);
[3] Even usage of coatings or surfaces that are not used to control or prevent attachment of organisms, where applicable.
Is there a need for inspection in the biofouling management process? Yes. Ship-specific monitoring of risk parameters can identify potential higher risk for biofouling, ie a part of an optimised regime for biofouling management, see Paragraph 1.7.
What is the danger of conducting in-water cleaning? There is a risk of releasing invasive species into the water, see Paragraph 1.7. Waste substances which are dislodged from the ship during the cleaning operation should be collected, see Paragraph 1.7.
What do the Guidelines provide for cleaning actions? It is based on a fouling rating number with the overall aim of minimising the risk of transfer of invasive aquatic species. Maintenance and ship recycling should be conducted with sufficient measures to avoid released of any invasive aquatic species in the water, see Paragraph 1.7.
Other than Biofouling Guidelines, what other frameworks are relevant for minimising the transfer of invasive aquatic species? There are two frameworks to consider:
[1] International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (BWM Convention), see Paragraph 1.8.1;
[2] International Convention on the Control of Harmful Anti-Fouling Systems on Ships, 2001 (AFS Convention), see Paragraph 1.8.2.
What are the practical advantages of biofouling management practices? Under Paragraph 1.9, the following have been identified by IMO’s 2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP), see MEPC.346(78), and IMO’s 2023 Strategy for the Reduction of Green House Gasses from Ships, see MEPC.377(80):
[1] Improvement of a ship’s hydrodynamic performance;
[2] Enhancing energy efficiency and reducing air emissions from ships.
What was the function of the GEF-UNDP-IMO GloFouling Partnership Project? It was part of a wider effort by IMO, in collaboration with the United Nations Development Programme (UNDP) and the Global Environment Facility (GEF). The aim was to build capacity in developing countries for implementation of the IMO Biofouling Guidelines and other relevant guidelines to minimise the transboundary introduction of invasive aquatic species, with the additional benefits in the reduction of greenhouse gas emissions from global shipping, see Paragraph 1.10.
SECTION 2 - DEFINITIONS
The definitions in Paragraph 2.1 start alphabetically from Anti-Fouling System, and end with Water Substances. Here is a selection of important technical terms:
[1] Anti-Fouling system (AFS) - a mechanism (eg coat, paint, surface treatment, surface or device) that is used to control or prevent attachment of organisms;
[2] Biofouling - the accumulation of aquatic organisms such as microorganisms, plants and animals on surfaces or structures immersed in or exposed to the aquatic environment. Biofouling can include pathogens.
[3] Dry-dock cleaning system - the cleaning of the submerged areas when the ship is out of water.
[4] Fouling rating - allocation of a number for a defined inspection area of the ship surface based on a visual assessment, including:
[a] Description of biofouling present; AND …
[b] Percentage of macro-fouling coverage.
[5] Invasive aquatic species - non-native species to a particular eco-system which may pose a threat to human, animal and plant life, economic and cultural activities and the aquatic environment.
[6] Macrofouling - biofouling caused by the attachment and subsequent growth of visible plants and animals or structure and ships exposed to water. Macrofouling consist of large, distinct multicellular individuals or colonial organisms visible to the human eye, such as:
[a] Barnacles;
[b] Tubeworms;
[c] Mussels;
[d] Fronds / filaments of algae;
[e] Bryozoans;
[f] Sea squirts;
[g] Other large attached, encrusting or mobile organisms.
[7] Microfouling - biofouling caused by:
[a] Bacteria;
[b] Fungi;
[c] Microalgae;
[d] Protozoans;
[e] Other microscopic organisms that creates a biofilm also called a slime layer.
SECTION 3 - APPLICATION
Who are the targeted ‘Stakeholders’? Paragraph 3.1 states that the Guidelines are directed at the following:
[1] Ship designers;
[2] Shipbuilder;
[3] Anti-fouling paint manufacturers and suppliers;
[4] States, including environmental and regulatory agencies;
[5] Classification Societies;
[6] Shipowners;
[7] Ship operators;
[8] Charterers;
[9] Shipmasters;
[10] Port Authorities;
[11] Ship cleaning and maintenance operators;
[12] Inspection organisations;
[13] Ship repair;
[14] Dry-docking re-cycling facilities;
[15] Any other interested parties.
How are alternative procedures, methods or actions taken to meet the objectives of the Guidelines which are not described to be dealt with? This should be reported by Members to IMO and to be taken into account in future reviews of the Guidelines, as appropriate, see Paragraph 3.2.
What is the approach for owners and/or operators of recreational craft of less than 24 metres in length? There should be a separate guidance document based on these Guidelines, using terminology appropriate for that sector, eg Guidance for minimizing the transfer of invasive aquatic species as biofouling (hull fouling) for recreational craft (MEPC.1/Circ.792), see Paragraph 3.3.
Are there circumstances where the Guidelines are not relevant? Yes, eg where ships operate only in the same waters in which the biofouling was accumulated. However, although there is no risk of introducing invasive aquatic species, measures to avoid discharge of harmful waste substances during the cleaning may still be relevant, see Paragraph 3.4.
Are there circumstances where an inspection regime may not be relevant to a ship? Yes, when the ship has remained idle from a longer period. However inspection and reactive cleaning may be needed before the ship is reactivated to reduce the risk of biofouling, see Paragraph 3.5.
SECTION 4 - OBJECTIVES
[1] Minimise the transfer of invasive aquatic species through biofouling on ships, see Paragraph 4.1.
[2] Safeguard the obligation under the UN Convention on the Law of the Sea (UNCLOS)(see Paragraph 4.2), in particular:
[a] Article 194 - prevent, reduce and control pollution of the marine environment;
[b] Article 195 - to not transfer (directly to indirectly) damage or hazards from area to another, or to transform one type of pollution into another;
[c] Article 196 - preventing the intentional or accidental introduction of species (alien or new) to a particular part of the marine environment.
[3] Providing a globally consistent approach to stakeholders on the control and management of biofouling;
[4] Minimising the risk of transferring invasive aquatic species from biofouling on ships;
[5] Reduction in emission to air from ships due to lower fuel demand in operation as a result of a clean hull.
SECTION 5 - DESIGN AND CONSTRUCTION
Is initial ship design and construction the most comprehensive, effective and long-lasting means to minimize ship biofouling risks? Yes, especially when the ship is significantly modified as identified in Paragraph 5.1:
[1] As far as practical, avoidance of small niches and sheltered areas, see Paragraph 5.1.1;
[2] Rounding and/or bevelling of corners, gratings and protrusions to promote more effective coverage of AFC, see Paragraph 5.1.2;
[3] Hinging of gratings to enable diver access, see Paragraph 5.1.2;
[4] Capacity to block off the sea chest for cleaning and treatment, see Paragraph 5.1.3;
[5] Designing internal seawater cooling systems with minimum bends and flanges, see Paragraph 5.1.4;
[6] Dead ends should be avoided in cross-over piping between cooling and general service systems, see Paragraph 5.1.4;
[7] Avoiding stagnant water with fully integrated standby pumps and piping, see Paragraph 5.1.4.
SECTION 6 - ANTI-FOULING SYSTEM (AFS) INSTALLATION AND MAINTENANCE
Are anti-fouling systems (AFS) effective at minimising biofouling on a ship’s submerged surfaces? Yes, especially on hull and niche areas, see Paragraph 6.1.
Why usage of AFS is important? There are restrictions in use of certain substances in Anti-Fouling Coating (AFC) which are regulated by the AFS Convention, see Paragraph 6.2.
Where should AFS be installed? On all submerged surfaces on a ship where biofouling may attach, see Paragraph 6.3.
Why are there so many AFS variants? AFS is designed for different ship operating profiles, eg some suitable for hull, and others for niche areas. Hence this requires different maintenance activities, see Paragraph 6.2.
What are the factors to be taken into account when choosing an AFS? A summary from Paragraph 6.3 is as follows:
[1] Ship design and construction, see Paragraph 6.3.1;
[2] Active ingredients of AFC, see Paragraph 6.3.2;
[3] Operating profile, see Paragraph 6.3.3;
[4] Aquatic environment, see Paragraph 6.3.4;
[5] Cleaning method, see Paragraph 6.3.5;
[6] Maintenance, see Paragraph 6.3.6;
[7] Legal requirements, see Paragraph 6.3.7.
What is the leading consideration when installing an AFS in hull and niche areas? Follow the manufacturer’s guidelines, see Paragraph 6.4.
What care should be taken in preparing niche areas for the application of any AFC to ensure adequate adhesion and coating thickness? According to Paragraph 6.5, particular attention should be given to the following:
[1] Corners, edges, pipes, holding brackets and bars of gratings;
[2] Smoothing and coating be done with adequate coating thickness to optimise system effectiveness;
[3] Touch up to ensure film thickness or a higher -grade AFC.
What are the recommended measures for the installation of AFS in a niche area? The following niche areas are listed in Paragraph 6.6:
[1] Sea Chest, see Paragraph 6.6.1;
[2] Bow and stern thrusters, see Paragraph 6.6.2;
[3] Rudder hinges and stabilizer fin apertures, see Paragraph 6.6.3;
[4] Propeller and shaft, see Paragraph 6.6.4;
[5] Stern tube seal assemblies and the internal surfaces of rope guards, see Paragraph 6.6.5;
[6] Cathodic protection anodes, see Paragraph 6.6.6;
[7] Pitot tubes, see Paragraph 6.6.7;
[8] Sea inlet pipes and overboard discharges, see Paragraph 6.6.8.
What is the importance of ship-specific Biofouling Management Plan (BFMP)? Based on the recommendations of the AFS’ manufacturer, it provides in Paragraph 6.7, the following:
[1] Necessary measures to ensure that AFS remain effective over the specified docking interval;
[2] Recommendations on how to return the AFS to optimal performance.
What information are manufacturers of AFS encouraged to provide information on? Paragraph 6.8 lists down the following details which are encourage to be in ships specific BFMP:
[1] Cleaning methods;
[2] Maintenance;
[3] Upgrade protocols specific to AFS;
[4] Inspection details;
[5] Repair details.
Why reinstalling, reapplying or repairing the AFS should be made in accordance with manufacturer’s guidance? These measures for surface preparation facilitate good adhesion and durability, see Paragraph 6.9.
Why should positions of dry-docking blocks and supports be varied at each dry-docking? These arrangements ensure the areas under the blocks are painted with an AFC, at least at alternate dry docking, see Paragraph 6.10.
What happens when it is not possible to alternate the position of dry-docking support strips? These areas should be specifically considered and managed by other means, eg the application of specialized coatings or procedures or measures for areas based on the past arrangement of dry-docking support strips to shift their position step by step for each dry-docking, see Paragraph 6.10.
Is there a list of non-exhaustive list of additional recommended measures for reinstallation or reapplication of AFS in niche areas? Paragraph 6.12 provides the following list:
[1] Any areas prone to coating damage at the bow and stern thrusters, see Paragraph 6.12.1;
[2] Recesses within rudder hinges and behind stabilizer fins, see Paragraph 6.12.2;
[3] Gratings located in sea chests, see Paragraph 6.12.3.
SECTION 7 - CONTINGENCY ACTION PLANS
What should monitoring of hull / fuel performance during ship operation identify? Possible increase in biofouling accumulation, ie this higher risk should lead to contingency actions such as inspection of submerged surfaces, see Paragraph 7.2.
What measures are to be included in ship specific contingency plan? Paragraph 7.3 provides for:
[1] Proactive action to lower the risk of biofouling accumulation owing to planned operational changes, see Paragraph 7.3.1;
[2] Corrective actions to operating profile, maintenance or other repair plans if there an early indication of elevated risk, see Paragraph 7.3.2;
[3] Determination of biofouling accumulation where monitoring of biofouling parameters identifies prolonged elevated risks, see Paragraph 7.3.3.
What should the contingency plan trigger if inspection identifies biofouling? Cleaning actions should be conducted, see Paragraph 7.5.
SECTION 8 - INSPECTION
Who should carry out inspections? Paragraph 8 identifies the following persons:
[1] Competent crew or personnel from organisations that use relevant inspection methods or equipment, see Paragraph 8.1.1;
[2] Inspection organisations who are to provide impartial inspection, see Paragraph 8.1.2;
[3] Organisations, crew or personnel competent for inspections as part of contingency actions, see Paragraph 8.1.3.
What should be the basis for inspection frequency or inspection dates (or date ranges) for in-water inspections during the in-service period of the ship? It should be based on ship-specific biofouling risk profile, including inspection as a contingency plan specified in the BFMP, see Paragraph 8.3.
What about ships not undertaking performance monitoring? The first inspection date should be within 12 months of application, re-application, installation or renewal of AFS to confirm their effective operation, see Paragraph 8.4.
What should be done Shem AFS is found to be not performing effectively after monitoring post-application, reapplication, installation or renewal? The evidence of non-performance could be found in increased fuel consumption. In response, an inspection should be carried out to confirm the condition of the AFS and level of bio-fouling. This should be done ‘as soon as practical or possible. An aseessment should be made in line with the BFMP and contingency action plan, see Paragraph 8.5.
What happens when there is adequate performance of AFS as revealed through monitoring? The inspection could be conducted up to 18 months after application, reapplication, installation or renewal. Note that such monitoring may not reflect the level of biofouling in all niche areas, see Paragraph 8.5.
Should subsequent inspections occur every 12-18 months, and why? Yes, as it is needed to confirm the continued effectiveness of ageing or damaged AFS, see Paragraph 8.6.
Should in-water inspections seek to coincide with existing subsea operations (eg underwater inspections in lieu of dry dock or any other in-water inspections), including any unscheduled subsea operations? YES !!! , see Paragraph 8.6
What if no AFS are installed in areas of the ship and no other measures are undertaken such as in-water cleaning or propeller polishing, how often should inspections occur? The inspections should be more frequent, ie less than 12 months, in order to manage the risk of biofouling accumulation, see Paragraph 8.6.
When should more frequent inspections occur more frequently, eg biannually? This should be done until dry docking and reciting of AFC if high levels of biofouling are identified during an inspection, and there are reasons to suspect issues with the AFS’s effectiveness, see Paragraph 8.7.
What is the importance of ‘in-water’ inspections? To determine the level of bio-fouling of the hull, niche areas and the condition of the AFS, especially in areas of the highest foul rating identified in the inspected areas, see Paragraph 8.8.
What are the three circumstances that deserve further inspection? The following are identified by Paragraph 8.9:
[1] Ratings of the type an extent in line with Table 1, see Paragraph 8.9.1. Note that these are the following descriptions found in Table 1, see Annex 17, page 16:
[a] No fouling - Rated O;
[b] Microfouling - Rated 1;
[c] Light macrofouling - Rated 2 (1-15 percent of surface);
[d] Medium macrofouling - Rated 3 (16-40 percent of surface);
[e] Heavy macrofouling - Rated 4 (41-100 percent of surface).
[2] Condition of the AFC on the hull and in niche areas described in Paragraph 8.7 above, rated in accordance with Table 4 definitions, see Paragraph 8.9.2. Note, Table 4 is found in Annex 17, page 33. It takes a look at the following areas:
[a] Hull below the waterline;
[b] Port vertical side;
[c] Starboard vertical side;
[d] Flat bottom front;
[e] Flat bottom mid;
[f] Flat bottom aft;
[g] Bow;
[h] Bow thruster;
[i] Bilge keels;
[j] Sea chest gratings;
[k] Stern;
[l] Propeller and its shaft;
[m] Ruder and rudder shaft;
[n] Discharge pipes;
[o] Rope guards;
[p] Sounders / instruments;
[q] Sacrificial anodes.
Also note that the AFC condition in Table 4 is also described with the following matrix:
[a] Intact and effective in preventing biofouling;
[b] Failure of adhesion between a coating and a metallic surface;
[c] Blistering in coating;
[d] Cracks in coating;
[e] Cold flow resulting in irregular coating thickness;
[f] Delamination / peeling / detachment between coatings;
[g] Polishing off coating during the ship’s operation (beyond specifications);
[h] Grounding / general damage to coating.
[3] Functionality of the MGPS (ie Marine Growth Prevention System) in niche areas, see Paragraph 8.9.3.
Which areas should be a priority during an inspection? Niche ares in the ship specific BFMP (ie Bio Fouling Management Plan), see Paragraph 8.10.
Should condition of the AFS on the hull and niche areas be observed during the inspection and reported? YES !!! Recommended action and relevant procedures are found in Tables 4 and 5. Note, in particular Table 5 (see Annex 17 at page 34) targets the following ‘typical niche areas’:
[a] Bow;
[b] Bow thruster;
[c] Bilge keels;
[d] Sea chest gratings;
[e] Stern;
[f] Propeller and its shaft;
[g] Rudder and its shaft;
[h] Discharge pipes;
[i] Rope Guards;
[j] Sounders / instruments.
Note, Table 5 documents the following conditions of MGPS:
[i] Intact and effective in preventing biofouling;
[ii] Calibration / maintenance required;
[iii] Non-effective to prevent biofouling.
Should an inspection report be prepared? YES !!! A copy should be available on board and listed / linked in the Biofouling Record Book (BFRB), see Paragraph 8.12.
SECTION 9 - CLEANING AND MAINTENANCE
Although cleaning is important to remove biofouling, what are its shortcomings? There are several identified in Paragraph 9.1:
[1] It may damage the AFC;
[2] Coating service lifetime may be shortened;
[3] AFC may release harmful waste substances;
[4] Invasive aquatic species may be released into the environment.
Why is comprehensive testing of cleaning systems or processes necessary? Paragraph 9.2 explains that:
[1] It is necessary to understand the cleaning performance;
[2] To capture efficiency;
[3] Determine whether there are release of harmful waste substances;
[4] Improve knowledge on prevention of release of viable fragments, spores and other parts of biofouling organisms that have potential to be invasive.
Is continuous development of in-water cleaning necessary? YES !!! It is a complex activity to be managed appropriately. International standards have to be continuously developed and published in a stand alone document to the Guidelines, see Paragraph 9.3.
Is proactive cleaning relevant? YES, especially periodically on the ship’s hull and niche areas, or other submerged areas, prior to macrofouling growth, see Paragraph 9.4.
What should operators undertaking proactive cleaning take into account? Paragraph 9.5 contains the following reminder:
[1] Awareness of local regulations;
[2] Regulations regarding the discharging of biofouling and waste substances into the marine environment;
[3] Location of sensitive areas, eg Marine Protected Areas.
Should procedures for proactive cleaning and frequency be described in the BFMP? Yes !!! Especially all proactive cleaning and any determination of biofouling level prior to the cleaning, see Paragraph 9.6.
What are reactive cleaning systems? Systems that physically remove micro and macro-fouling from the hull and niche areas. Usage can be made of available methods, and others under development, see Paragraph 9.7
What is the relevance of inspection results and contingency action in reactive cleaning? Such cleaning should be conducted based on inspection results and contingency actions. However, cleaning with capture may be used to manage any rating level, see Paragraph 9.8.
What are the features of reactive cleaning? Paragraph 9.9 identifies the following:
[1] The reactive cleaning method should be compatible with the AFC in order to minimize damage of the AFC, see Paragraph 9.9.1;
[2] The cleaning should aim to achieve a foul rating of equal of less than 1 for the cleaned area, see Paragraph 9.9.2;
[3] The reactive cleaning should strive for effective collection and safe disposal of all biofouling material and waste substances when reactive cleaning is performed in water or at dry dock, see Paragraph 9.9.3;
[4] The cleaning should be conducted in an area accepted by the relevant authority for this activity, see Paragraph 9.9.4.
What measures are regarded as adequate management for biofouling in nice areas? Paragraph 9.10 makes stipulations for the following:
[1] Preventing accumulation of biofouling in niche areas by installation of any MGPS and its maintenance to ensure effective operation, see Paragraph 9.10.1;
[2] Maintaining operational efficiency and minimize macrofouling accumulation with regular polishing (with capture of debris) of uncoated propellers, see Paragraph 9.10.2;
[3] Regulatory compliance with appropriate treatment of internal seawater cooling systems and discharge of any treated water, see Paragraph 9.10.3;
[4] Usage of toxic and phosphate-free, biodegradable and non-hazardous soap, cleaner or detergent for surfaces, see Paragraph 9.10.4.
How should biological waste and waste substances be disposed of and treated? Such captured waste should be disposed of in a safe and environmentally safe manner, in accordance with local requirements, see Paragraph 9.12.
What should be done with a copy of the cleaning report? Both it or a similar outcome in a digital tool should be made available on board the ship, and the activity entered into the BFRB, see Paragraph 9.14.
What measures should be adopted by ship recycling facilities? Such facilities should adopt measures that are consistent with applicable national and local laws / regulations. This is to ensure that biofouling organisms or waste substances are not released into the local aquatic environment, see Paragraph 9.15.
What sort of plan should ship recycling facilities develop? A plan to minimize release of biofouling organisms and/or waste substances. In particular that hull and niche areas should be cleaned prior to recycling to avoid release of viable biofouling organisms or waste substances, see Paragraph 9.16.
SECTION 10 - BIOFOULING MANAGEMENT PLAN (BFMP)
Who bears responsibility for a ship-specific BFMP? Shipowners, ship operator and ship masters should have a recommended BFMP on board every ship, see Paragraph 10.1.
Where should be information for the BFMP be sourced from? From designers, shipbuilders, shipowners, AFC and MGPS manufacturers, recognized organizations and suppliers, see Paragraph 10.1.
At what rating should an effective BFMP be maintained at? The aim tis to maintain a recommended fouling rating of equivalent or less than 1, see Paragraph 10.2.
What should a ship-specific BFMP include? According to Paragraph 10.3, it should include, but not necessarily limited to the following:
[1] Proper implementation of the plan by an identified officer or person in particular position (eg chief engineer) responsible for the BFMP, see Paragraph 10.3;
[2] Location and details of installed AFS, see Paragraph 10.3;
[3] Suitably selected operating conditions for recommended selected AFS to avoid deterioration of AFC, taking into account for eg temperature, salinity and speed etc, see Paragraph 10.3.3;
[4] Throughout the Arc lifetime, details of expected AFC efficacy, including the need for inspection or maintenance where relevant, see Paragraph 10.3.4;
[5] Description of monitoring on biofouling risk parameters, see Paragraph 10.3.5;
[6] Regime for cleaning (if any), see Paragraph 10.3.6;
[7] Details offhand nice areas where biofouling may accumulate, see Paragraph 10.1.7
[8] Schedule for fixed inspections of areas, see Paragraph 10.3.8;
[9] If triggered by inspection results, procedures for reactive cleaning actions that should be performed, see Paragraph 10.3.9;
[10] When relevant, the manufacturer’s instruction should be followed in a regime for repairs, maintenance and renewal of AFS, see Paragraph 10.3.11;
[11] To minimize effectiveness in biofouling, the manufacturer’s instruction for monitoring and maintenance of MGPS should be followed, see Paragraph 10.3.12;
[12] Documenting the details of biofouling activities through documentation / reports, see Paragraph 10.3.13.
How could efficient and sustainable biofouling management be facilitated? Through planning with gathered information that allows the evaluation and comparison of the cost-effectiveness of alternative strategies. Note, that the optimal solution is case-specific and should be considered in the light of several aspects, see Paragraph 10.4.
How could more frequent inspections be triggered? When monitoring of the hull and the biofouling risk parameters determines that a risk of biofouling is higher than predicted in the BFMP, see Paragraph 10.5.
Should inspection results be shared with stakeholders? Yes, if there is agreement to do so if relevant for the purposes of improvement, . Note, that inspection organizations are encouraged to share inspection results with AFS manufacturers, as this can increase the efficiency of biofouling management and inspections, see Paragraph 10.6.
Should the effectiveness of the management actions in place be reviewed following inspections and cleaning? YES !!! According to Paragraph 10.7, a review of inspections and cleaning should be made to determine the effectiveness of management actions, ie whether it is ineffective or deficient. Items that should be evaluated include:
[1] Usage of proactive cleaning methods to minimize biofouling methods, see Paragraph 10.7.1;
[2] The schedule for biofouling inspections, see Paragraph 10.7.2;
[3] Ability of MGPS to minimize biofouling, see Paragraph 10.7.3;
[4] AFS Performance, see Paragraph 10.7.4;
[5] Outcome of reactive biofouling management procedures, such as:
[a] Efficacy of biofouling removal (ie there should be no areas missed), see Paragraph 10.7.5.1; … AND …
[b] Accessibility for reactive cleaning in niche areas, see Paragraph 10.7.5.2.
Is there a format for the BFMP? Yes. One is set out in Appendix 3, see Paragraph 10.8.
SECTION 11 - BIOFOULING RECORD BOOK (BFRB)
Who has the responsibility of overall record-keeping for ship specific biofouling management activities in a BFRB? It is the responsibility of the shipowners, ship operators and/or shipmasters, see Paragraph 11.1.
Information from which parties should be included on biofouling management actions? Paragraph 11.1 identifies the following persons:
[1] AFS manufacturers and suppliers;
[2] Ship cleaning and maintenance operators;
[3] Inspection organizations;
[4] Ship repair and dry docking facilities.
What is recommended to be done with the BFRB? To be retained on board for the life of the ship, see Paragraph 11.2.
What should the book record? Details and reports of all inspection and maintenance activities undertaken for all hull and niche areas, see Paragraph 11.2.
What form should the BFRB take? Paragraph 11.2 recommends the following:
[1] Physical or electronically;
[2] Stand alone document; OR …
[3] Integrated (in part or in full) into the existing ships’ operational and procedural manuals and/or planned maintenance systems.
What should assist the shipowner and operator evaluate the efficacy of the ship specific AFS and biofouling management measures on the ship? The BFRB, ie the Bio Fouling Record Book, see Paragraph 11.3
What details should recorded in the BFRB? Paragraph 11.4 identifies the following details:
[1] In addition to the recordings in the International Anti-Fouling System Certificate, the details of repair and maintenance to the AFS. This includes [a] date, location and areas of the ship affected; [b] percentage of the ship that was re-coated with AFC, see Paragraph 11.4.1;
[2] Date, location and areas affected, including details of repair and maintenance to the MGPS, see Paragraph 11.4.2;
[3] The inspection report plus [a] initial date; [b] final date; [c] duration in hours/days; [d] location of in-water inspections; [e] inspection report, see Paragraph 11.4.3;
[4] Initial date, final date, duration in hours/days and location of cleaning (in water or in dry dock), including a cleaning report, see Paragraph 11.4.4;
[5] Details of when the ship is laid up or inactive for extended periods of time, ie when a ship has been operating outside its normal operating profile, see Paragraph 11.4.5;
[6] Inspection intervals and the associated performance monitoring parameters, see Paragraph 11.4.6.
[7] A copy of the cleaning report (as set out in Appendix 2), see Paragraph 11.4.7;
[8] Date, time and location of any contingency actions taken, see Paragraph 11.4.8.
Note, refer to Appendix 4 for the format of the BFRB, see Paragraph 11.5.
SECTION 12 - DOCUMENTATION AND DISSEMINATION OF INFORMATION
What format should the documentation be kept in? Relevant plans and reports, can be developed, maintained and kept in electronic format, see Paragraph 12.1.
What information are States encouraged to provide? Information on the location and the terms of use of proactive cleaning, inspection, reactive cleaning services and facilities to comply with these Guidelines, see Paragraph 12.2.
Should States that require inspection or cleaning prior to arrival in their territory inform IMO? Yes, see Paragraph 12.2.
What information should be communicated by the States? Member States and relevant stakeholders are encouraged to communicate [a] the outcome of testing cleaning systems; [b] the applicable test standards, see Paragraph 12.2
Should State authorities provide ships with timely, clear and concise information on biofouling management measures and cleaning requirements being applied? Yes, States should ensure that these are widely distributed. This enable shipowners and operators to become familiar with all requirements related to biofouling by requesting such information from their port or shipping agents or competent authorities, see Paragraph 12.4.
Why is verification and detailed information important? It enables accurate information to be obtained by the ship prior to arrival that enables the requirements needed to obtain entry clearance, see Paragraph 12.5.
Should reasons why ships could not apply the Guidelines be recorded? Yes, in order to monitor the effectiveness of the Guideline in the evaluation process, for example ship design, construction, operation, and particularly ships’ safety or lack of information concerning the Guidelines, see Paragraph 12.6.
SECTION 13 - TRAINING AND EDUCATION
What sort of training is appropriate for ships’ masters and crew, in-water cleaning or maintenance facility operators and those surveying or inspecting ships? Suggestions in Paragraph 13.1 include:
[1] Records and logs maintenance, see Paragraph 13.1.1;
[2] The impact of biofouling from invasive aquatic species, see Paragraph 13.1.2;
[3] Threats posed by not applying management procedures, and the benefits of managing biofouling, see Paragraph 13.1.3;
[4] Associated safety procedures to biofouling management measures, see Paragraph 13.1.4;
[5] Relevant health and safety issues, see Paragraph 13.1.5.
Should the Guidelines be included in the syllabuses for marine training organizations? Yes, in order to create awareness of the Guidelines, see Paragraph 13.2.
SECTION 14 - OTHER MEASURES
Why should ships enjoy a smooth flow going in and out of ports? Avoiding ships having to wait off-shore ensures that AFS operates as effectively as possible, see Paragraph 14.1.
Can States apply other measures to ships within their jurisdiction for the purposes of providing additional protection to the marine environment (or in emergency situations)? YES, when managing emergency situations for biofouling and also biofouling management, see Paragraph 14.2.
Should the States consider Guidelines when developing other measures and/or restrictions for managing ships' biofouling? YES !!! see Paragraph 14.3.
What should States do when other measures are being applied? Notify IMO of the specific requirements, which can then be dessiminated to other States and non-governmental agencies where appropriate, see Paragraph 14.4.
Should States ensure that the safety of the ship and crew are not at risk when there is application of other measures? YES !!!, see Paragraph 14.5
THE VARIOUS APPENDICES
APPENDIX 1 - ASSESSMENT OF BIOFOULING RISK
The information here shows ways in which to take a proactive approach to biofouling for hull and niche areas by monitoring various risk parameters, Paragraph 1.
Paragraph 2 identifies niche areas which should be identified for monitoring (from bow to stern of the vessel):
[1] Areas prone to paint damage;
[2] Anchors, its chains and wells;
[3] Bow thruster;
[4] Bilge keel;
[5] Dry-docking support strips;
[6] Internal water systems;
[7] Sea chest and gratings;
[8] Intake or outflow openings;
[9] Anodes;
[10] Propeller and shaft;
[11] Rudder, shaft and hinge.
Paragraph 3, identifies the relevant parameters for risk assessment:
[1] Changes in the propulsion power and fuel consumption may indicate a degradation of hull or propeller condition due to biofouling. But growth in niche areas may not be identified with this method;
[2] Deviation from maintenance / service regime elevates the risk profile for biofouling;
[3] Deviation from regular proactive cleaning or necessary reactive cleaning increases risk;
[4] Rate of biofouling also increases when the ship has extended idle time;
[5] Mechanical damage to anti-fouling systems should be evaluated as this also increases risk;
[6] Once an anti-fouling systems has exceeded its expected lifespan increases the risk profile for biofouling also-fouling.
APPENDIX 2 - INSPECTION AND CLEANING REPORTS
Who should prepare the inspection report? Generally, the inspection provider. For contingency actions where inspection is carried out, it can be prepared by the ship’s crew, see Paragraph 1.
What are the usual particulars that are found in a biofouling inspection report? Paragraph 2 stipulates the following:
[1] Particulars of the ship, eg name and IMO number;
[2] Date and place of inspection;
[3] Inspection / cleaning company’s name;
[4] List of the hull and niche areas which have been inspected;
[5] Equipment used in inspection, including list of divers and ROV operators;
[6] Inspection conditions, eg duration and estimated visibility underwater;
[7] Inspection / cleaning company’s authorised person and his/her signature;
[8] Commencement and end times of the inspection;
[9] Results of the inspection, including type of biofouling and quantitative assessments of biofouling cover area inspected (ie percentage of cover);
[10] Anti-fouling coating (AFC) condition observed during inspection, reported and categorised;
[11] Condition of the marine growth prevention system (MGPS) during inspection which is reported and categorised;
[12] Photos and video submitted or used ion a digital assessment tool to provide evidence of biofouling cover area-fouling.
How is the condition of AFC categorised? In Table 4, see Annex 17, p 33, the categorisation is made as follows:
[1] Intact and effective in preventing biofouling;
[2] Failure of adhesion between a coating and a metallic surface;
[3] Blistering in coating;
[4] Cracks in the coatings;
[5] Cold flow resulting in irregular coating thickness;
[6] Delamination / peeling / detachment between coatings;
[7] Polishing off coating during the ship’s operation (beyond specifications);
[8] Grounding / general damage to coating.
How is the condition of MGPS evaluated? This is the description according to Table 5, Annex 17, p 33:
[1] Intact and effective in preventing biofouling;
[2] Calibration / maintenance required;
[3] Non-effective to prevent biofouling.
APPENDIX 3 - EXAMPLE FORM OF BIOFOULING MANAGEMENT PLAN
Details which should be in a Bio-Fouling Management Plan (BFMP):
[1] Most recent and next scheduled dry-docking, see Annex 17, p 38;
[2] Operating profile of the ship, including (see Annex 17, p 39):
[a] Operating speed;
[b] Trading areas;
[c] Operating areas, including climates zones in which the ship will operate;
[d] Typical salinities of operating area;
[e] Whether the installed AFS are suitable for the typical operating profile of that vessel;
[3] Description of the hull and niche areas where biofouling may accumulate, see Annex 17, pp 39-40.
[4] Places where anti-fouling systems (AFS) have been installed, see Annex 17, p 42;
[5] Inspection schedule of the hull and niche areas, see Annex 17, p 43;
[6] Reactive cleaning methods and areas subjected to it;
[7] Proactive cleaning and areas where it is applied, plus its schedule.
How are the risk parameters for bio fouling monitored? Digital monitoring tools can be applied to the following, see Annex 17, p 46-53:
[1] Deviation from speed specifications;
[2] Deviation from salinity specifications acceptable for the AFS;
[3] Deviation from the temperature range specifications;
[4] Deviation from the maintenance / service regime of AFC;
[5] AFC damage;
[6] Deviation from the maintenance / service regime of the MGPS;
[7] Downtime / malfunction of MGPS;
[8] Downtime / malfunction of other AFS;
[9] Exceeding expected lifetime of AFS;
[10] Deviation from regular proactive cleaning;
[11] Deviation from necessary reactive cleaning;
[12] Extended ship idle time (berthed, anchored, moored);
[13] Performance loss as per Performance Monitoring System;
[14] Downtime / malfunction of proactive cleaning.
What should be done for the capture and disposal of waster? It should be disposed of and/or treated in a safe and environmentally sound manner, in accordance with local regulations. The main objective should be to minimize the transfer of invasive aquatic species.
APPENDIX 4 - EXAMPLE FORM OF BIOFOULING RECORD BOOK
Among the broad areas identified in this book are as follows (see Annex 17, pp 54-62):
PART I - Biofouling Management Activities
[1] Proactive cleaning;
[2] Inspection;
[3] Reactive cleaning;
[4] Additional operational procedures.
PART II - Monitoring of Biofouling Risk Parameters
[1] When the ship operates outside the expected operating profile specified in the BFMP (eg speed, temperature or salinity);
[2] Maintenance / service or damage to AFC;
[3] Maintenance / service or downtime / malfunction of MGPS;
[4] Maintenance / service or downtime / malfunction of other AFS;
[5] Deviation from regular use of expected proactive cleaning as specified in the BFMP;
[6] Deviation from the necessary reactive cleaning as specified in the BFMP;
[7] When the ship is idle (berthed, anchored, moored) for a longer period;
[8] When the ship has performance loss as per Performance Monitoring System for a period beyond the expected period as specified in the BFMP;
[9] Other deviations.
Thank you for reading IMSML Website Article 14/2024
Stay tuned for the next IMSML Website Article 15/2025: Resolution MEPC.379(80) - 2023 Guidelines for the Development of the Inventory of Hazardous Materials
Signing-off for today,
Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT
Professor of Maritime and Transport Law
Head of the Centre for Advocacy and Dispute Resolution
Faculty of Law
Universiti Teknologi MARA Shah Alam
Selangor, Malaysia
Tuesday, 8 April 2025
Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my